Ethical Procurement Policy

Ethical Behaviour

It is the duty of all employees, but particularly those involved in the procurement function, to maintain and be seen to maintain an unimpeachable standard of integrity in all business relationships, both internally and externally and firmly reject those practices which might reasonably be deemed improper. This will result in the Company being trusted and respected for not only carrying out its business efficiently but in a fair and reasonable manner and with integrity.

Our guiding principles are:

• That the conduct of staff should not foster the suspicion of any conflict between their Company duty and their private interest.
• That the action of employees should not give the impression to any member of the public, any organisation they deal with or their colleagues that they have been or may have been influenced by a gift or a consideration to show favour or disfavour to any person or organisation.
• That dealings with suppliers/contractors must at all times be honest, fair and even-handed.
• That ethical behaviour must be promoted and supported by appropriate systems and procedures.

Any improper approaches, whether in the form of inducements or threats, must be reported even if they are sufficiently ambiguous to allow an innocent construction.

Gifts, Hospitality, etc.

Only gifts of small intrinsic value or seasonal nature – pens, desk diaries for example – may be accepted from actual or potential suppliers.

Modest hospitality may be accepted if it could not be considered to have influenced the making of a business and/or procurement decision. For example, meals or refreshments must be of a modest kind and, if possible, the employee should pay for their own meal and claim for reimbursement.

Acceptance by employees of hospitality through attendance at relevant conferences and courses, or new product launches, is acceptable where it is clear the hospitality is corporate rather than personal.

Invitations to visit user sites, attend specialist conferences, association annual dinners, etc. should be treated with caution. Invitations extended to a spouse or other guest should be declined except in exceptional circumstances and only if approved by a Director. All invitations to sporting occasions and other functions with no business content should be reported and declined.

Declaration of Interest

Any personal interest (for example share-holding –  family or private relationship – or friendship) which may impinge or be construed to impinge on an employee’s ability to be impartial in exercising his/her duty in the Company’s interests must be declared immediately to the Director before any procurement activity is commenced.

The prior approval of the employee’s Director must be obtained before any employee may accept an invitation to act in the capacity of a Director or Consultant, or take up any employment with any company or private undertaking.

Conflicts of Interest

When dealing with suppliers, potential conflicts of interest may arise, for example spouses or other relatives may be employed by the company or supplier. Such potential conflicts should be reported to your Director.

Employees should avoid, as far as possible, in dealing with suppliers in their private affairs, particularly if this is likely to put them under some obligation to the supplier. It is essential that they ensure the supplier does not offer them any sort of deal which is not commonly available and which could be construed as a reward for actions taken in the course of their employment.

Employees who wish to enter into any private transaction with any contractor/agent or employee of a supplier must seek permission from a Director.

Fraud, Theft and Corruption

Fraud, theft and corruption are criminal offences defined as follows:

• Fraud – the false representation of facts with an intention to deceive or enable some person or organisation to gain unfair advantage. This includes the falsification of documents and the certification as true of facts known to be wrong.
• Theft – stealing or dishonest misappropriation of money or property.
• Corruption – acceptance of any gift or consideration as an inducement or reward.

Confidential Information

Commercially sensitive information must be kept confidential and never utilised for personal gain or to prejudice fair competition.

Offers of Employment

If an employee involved in procurement activity receives an offer of employment from anyone with whom he/she has been brought into contact by his/her official duties, he/she should advise a Director.

Confidential Reporting Code

It is the Company’s policy to support, protect and, where possible, preserve the anonymity of any of our employees that report apparently questionable activity, even if their fears subsequently prove to be unfounded. Early reporting is essential, so that where necessary, legal advice can be taken and both the individual and organisation protected.

Information

Employees are encouraged to access travel information which incorporates guidance on how they can be more sustainable and facilitates easy planning.  This gives Employees the opportunity to consider their travel options, the cost, times and also the carbon footprints.